Verizon Wireless petitions for WNP to disappear, pooling still OK

In a late July filing, Verizon Wireless (www.verizonwireless.com) asked the FCC (www.fcc.gov) to eliminate wireless carriers’ requirement to provide wireless number portability (WNP). The carrier wants the commission to retain requirements for number pooling, the allocation of numbers in thousand blocks, which is scheduled to begin on the same date, Nov. 24, 2002. The petition argues that carrier resources would be better spent toward pooling, which will help alleviate the nation’s number exhaustion.

Originally called for to help increase competition, Verizon argues that WNP is completely unnecessary, as the industry is already a model for fierce competition. In addition, WNP requires significant changes in customer service and intercarrier communication that would be burdensome to carriers.

“Forcing CMRS providers to incur the burden of these tasks would thus constitute an enormous waste of carrier resources and would be regulatory overkill of the worst magnitude,” the filing states.

At their core, number pooling and WNP share the same technology: location routing number (LRN) architecture. The first six digits of the 10-digit LRN identify which switch the call should go to. From those digits, the carrier can tell whether or not the number is in a pooled market. If it is, the typical method is abandoned, and the LRN method used. The seventh number then serves as the call’s travel agent.

“You look at the seventh number and let’s say it’s a 1,” said Ben Levitan, TSI (www.tsiconnections.com) manager, technology standards. “You check the database and find out that the 1000 block was pooled to carrier X – you know how to route the call and you don’t have to do a look up. It would be the same if someone calls 1999 or 1044 or 1111; the whole 1000 block has been pooled to carrier X.”

Switches don’t have the capacity to hold a database for the pooling look-up, so an inquiry will have to be sent to the number portability database to determine the block’s carrier, Levitan added.

Much the same process would be conducted with ported numbers – only any number could be ported, forcing carriers to do an inquiry for every number rather each block.

The industry is lucky that pooling uses the same LRN-technology required for WNP, Levitan said. It’s almost too good to be true. “It’s like a guy who builds a widget and then finds out there’s no market for the widget and he turns around and says ‘hey, you can use this widget for something else,’” Levitan said.

Changes for WNP, however, don’t stop at call routing. Portability is infamous for touching nearly every aspect of carrier operations; one carrier’s study determined that WNP would impact every facet of its operations, except payroll. Eliminating the WNP requirement would be a tremendous benefit to the industry, according to Levitan.

“Let’s say nothing changes between now and Nov. 24, 2002,” he said. “We’re going to spend a lot of time testing two parts of it, the routing and the administrative process. The administrative process is horrendous and if the FCC said ‘forget about portability,’ they would just drop the administrative process and continue on with the routing process – it would take a lot of the burden off.”

Verizon, though, ultimately wants WNP dropped because portability is not needed to increase competition among wireless carriers. The carrier argues that the commission’s own competition reports prove WNP’s futility and the industry’s outstanding competitiveness.

The three annual competition reports released since the FCC granted carriers forbearance until WNP’s current deadline all “show that competition has steadily increased – without CMRS LNP,” the filing reads. “If anything, these reports show that forbearance should now be made permanent, and that there is even less basis to impose the huge regulatory burden of LNP.”

“Increased competition should mean less regulation, not more,” Verizon states.

WNP was originally called for to not only increase competition among wireless carriers, but also between wireless and landline. The idea that customers might port their wireline numbers to wireless carriers has been the lone hope for an ROI from WNP. Verizon isn’t optimistic about that idea.

“There is no evidence that CMRS LNP would materially affect a landline customer’s decision about whether to retain landline service,” the filing states.

One might guess that the FCC could argue that WNP will improve already impressive competition in the wireless industry. That perspective won’t fly with Verizon.

“Assuming that portability, while not necessary for competition, would nevertheless enhance competition, the commission would still not be justified in enforcing the rule,” the filing states. “A speculative, marginal gain in competition would not justify the complexity or expense of providing LNP to CMRS customers. Customer choice is not impeded by personal attachment to a wireless phone number. The churn levels in the wireless industry prove as much.”